Privacy
Policy

1. Introduction

This Privacy Policy describes how SG Bolivia SRL ("we", "our", or "the Company"), with registered office in Santa Cruz de la Sierra, Bolivia, collects, uses, stores, and shares personal information in the context of Sg Sales ("the Service"), an automated sales assistance platform operating primarily through WhatsApp Business.

Sg Sales is designed to allow businesses ("Business Customers") to automate sales conversations with their own end customers ("End Users") using an AI-powered conversational agent. This policy applies to both Business Customers and End Users interacting with the system.

By using Sg Sales, you accept the practices described in this document.

2. Information we collect

2.1 Business Customer information

When a business contracts Sg Sales, we collect:

• Account information: business name, legal entity, tax ID (when applicable), country, industry vertical
• Contact information of the responsible party: name, email, WhatsApp number
• WhatsApp Business technical information: business phone number, Meta identifiers (phone_number_id, waba_id, business_portfolio_id)
• WhatsApp Business Platform API credentials (Meta), obtained through the official Embedded Signup flow
• Bot configuration: message templates, lead qualification criteria, product/service catalog

2.2 End User information

When an End User initiates conversation with a Business Customer via WhatsApp, we may process:

• End User's phone number (provided by Meta in each message)
• WhatsApp profile name (if publicly available)
• Content of exchanged messages (text, images, audio, video, documents, location)
• Metadata: send time, read status, message identifiers
• Commercial information voluntarily provided by the End User during conversation

2.3 Automatically collected information

• Service usage metrics
• Technical logs for diagnostics and audit
• Device and browser information when Business Customers access the admin panel

3. How we use the information

• Operate the conversational bot that responds to End Users on behalf of the Business Customer
• Transcribe audio messages and analyze multimedia content via AI services
• Qualify leads (BANT and SPIN scoring system)
• Sync conversations between WhatsApp and the Business Customer's admin panel
• Send automatic follow-ups to End Users who haven't responded within configured timeframes
• Generate reports and statistics for Business Customers
• Comply with legal obligations and resolve disputes
• Improve the Service through aggregated and anonymized analysis

We do not use conversation content to train our own or third-party AI models without explicit authorization.

4. Information sharing with third parties

We do not sell, rent, or commercialize personal information with third parties for marketing purposes.

5. Legal basis for processing

• Contract performance: to provide the Service to Business Customers
• Legitimate interest: to operate the bot, prevent abuse, generate aggregated statistics
• Consent: for End Users who voluntarily initiate conversation
• Legal compliance: when required by authority

6. Data retention

• Active conversations: while the Business Customer's account is active
• Conversations after cancellation: kept 90 days, then deleted
• Technical logs: 30 days
• Database backups: 30 days (rotating)
• Data required by legal obligations (billing, tax): up to 10 years per Bolivian legislation

7. Security

• Encrypted connections (HTTPS/TLS) in all communications
• Access tokens stored with bcrypt hashing
• Multi-tenant isolation in the database
• Restricted access to the admin panel via unique per-customer tokens
• Automated encrypted backups in external storage (Cloudflare R2)
• Sensitive change auditing via logs

8. Data subject rights

• Access the personal information we hold about you
• Rectify inaccurate or incomplete information
• Delete your personal data ("right to be forgotten")
• Object to the processing of your data
• Portability: receive your data in structured format
• Withdraw consent at any time
• Opt out by replying "BAJA", "STOP", or "UNSUBSCRIBE" to the chat

9. Contact

• Email: jsaid@sgbolivia.com
• WhatsApp: +591 77001196
• Address: Santa Cruz de la Sierra, Bolivia
• Responsible party: Jose Said Muñoz, on behalf of SG Bolivia SRL

We respond to requests within 15 business days.

10. International transfers

Sg Sales uses technology providers located outside Bolivia (United States, Europe). Data may be transferred to these jurisdictions under standard contractual clauses.

11. Minors

Sg Sales is not directed to persons under 18 years of age. We do not knowingly collect data from minors.

12. Changes to this policy

We may update this Privacy Policy. The current version will always be available at sg-ventas.com/privacy-en. Material changes will be communicated to Business Customers at least 30 days in advance via email.

13. Applicable law

This Policy is governed by the laws of the Plurinational State of Bolivia. Any dispute will be resolved before the competent courts of Santa Cruz de la Sierra.